tv Key Capitol Hill Hearings CSPAN November 14, 2013 5:00am-7:01am EST
review the important work of the agency to protect consumers and empower them to make responsible financial decisions, promote competition and especialnable ao financial services for all americans. the cfpb has made good progress in fulfilling its mission. it's undertaken critical analysis of the most common financial products in a consumer's life including mortgages, student loans, credit cards and deposit accounts and has taken action to improve the consumer experience with these products. for example for student loan, the bureau has focussed on key elements towards paying for college project which streamlines the college financial process through
extensive outreach to students and educators. the cfpb has also approach to be a strong enforcer of consumer laws and has shown on no tolerance policy for violators. since it opened just two years ago, it has obtained $700 million of refunds for harmed consumers. this would not be possible without the about your bureau's ability to collect data. it's the first federal agency to look atbout your bureau's ability to collect data. it's the first federal agency to look atout your bureau's ability to collect data. it's the first federal agency to look atut your bureau's ability to collect data. it's the first federal agency to look att your bureau's ability to collect data. it's the first federal agency to look at your bureau's ability to collect data. it's the first federal agency to look atyour bureau's ability to collect data. it's the first federal agency to look atour bureau's ability to collect data. it's the first federal agency to look atur bureau's ability to collect data. it's the first federal agency to look atr bureau's ability to collect data. it's the first federal agency to look at bureau's ability to collect data. companies that had no supervision and about which nobody hadded a quality
information. all of the other agencies collect data. the federal reserve, occ and fdic understand as does the cfpb that smart regulations need smart data. but we live in a world where more and more data about consumers is used by businesses and governmental like information security and data privacy must be safe guarded and encouraged by the burrabout you bureau's efforts to address these issues. earlier in year, the cfpb finalized rules to strengthen authori mortgage standards.earlier in y finalized rules to strengthen mortgage standards. these rules were well received, however, i remain interested in hearing from director cordray on how these will improve lending.
i look forward to hearing your expectations for compliance with these rules in january especially for small lenders. finally, the committee's exploration of housing finance reform is well under way. as we move forward, i'm interested to hear about your thought on the enter as of your mortgage rules including qm with the new system. and any unintended consequences. with that, i turn to the ranking member. >> thank you, mr. chairman. today we will hear from director cordray on the consumer financial protection bureau semiannual report. this hearing provides an opportunity to discuss the future of the agency and to evaluate its past performance. thank you director cordray for your -- for two recent actions that the agency has taken. back in the spring, it was
brought to our attention that the presence of enforcement attorneys attending on site supervisory examinations was negatively affecting the process and very rememberecently they a decision to remove the attorneys from examination. which will now examine free examination of information and ultimately result i believe in a better supervision. in addition, at a september house hearing, the director noted that the annual privacy notice requirement may be placing unnecessary burdens on institutions without much benefit for consumers. senators brown and johanns have a bill pending in the snenate t in addition of accomplish this. these actions were a move in the right direction and i appreciate director cordray taking them. consumer protection is vital. we are now three years removed from the accuracy of the bureau and while some growing pains have been expected, it is time
now for the bureau to be treated as a seasoned regulator. as a part of our oversight role, we expect all of our banking regulators to operate efficiently, to demonstrate transparency and to act responsibly. while i appreciate the positive steps the bureau has taken in recent months, it's also taken several actions that have been widely criticized. calling in to question efforts to meet those expectations. earlier this year, the bureau issued a bulletin on indirect auto lending that represents a major shift in policy. however, there was no public input prior to this change being made. this particular policy shift could ultimately increase the cost of credit and reduce options for financing when an individual goes to buy a car or a truck. a bipartisan group of senators has septembnt a letter last wee highlighting these concerns. cfpb is also very active in other areas. and with this increased activity, the bureau has the
responsibility to prevent potential regulatory burden and overreach, especially as it begins to supervise new markets and products. small institutions like those in idaho are being significantly affected by the shear volume of new cfpb regulations that they are forced to comply where as well as the constantly changing regulatory scheme. some simpgly lsimply do not ha the resources. in previous hearings, i've also raised my concerns of the big data collection of consumer financial information. examples of personal privacy failures by our federal agencies have only increased since that time. just last week, it was announced that the internal revenue service was complacent in a huge identity theft scheme that left 1.6 measure tamerican taxpayers vulnerable. and that's just one consequence. basic questions still remain to
be answered. how many credit card accounts is the bureau following on a monthly basis? and who at the agency holds the keys to view and use this data? the bureau's lack of clearly identifiable and arctticulated purpose is also troubling. for these reasons, i requested that the government accountability office investigate to determine its purpose, scope, intended use and specific legal authority. data collection touches every aspect of the bureau's activities. as a result, this committee need as clear and complete understanding of this process. thank you, mr. chairman. >> thank you, senator crapo. are there any other members who would like to give -- mr. richard cordray, as director of
the consumer financial protection bureau, mr. cordray, you may begin your testimony. >> members of the commitity, thank you for inviting me to testify about the fourth semiannual report of the consumer financial protection bureau. since we opened our doors just over two years ago, the bureau has been focused on make consumer financial markets work better for consumers and honest businesses. the report we're discussing today describes the bureau's efforts to achieve this vital mission through fair rules, consistent oversight, appropriate enforcement of the law and broad based consumer especially gam especially gaemg, the bureau is helping to put more than $750 million back in the pockets of millions of consumers. these include a refund of more than $6 million to tens of thousands of u.s. service
members in a case involving the military allotment system. because of our supervisory work, financial institutions are making changes to the compliance management systems to prevent violations and reduce risk to consumers. in addition, because of our efforts, a number of entities have self identified violations. and are providing restitution to even more consumers. that is good work by our supervision team, good business practice for the companies, and good for consumers who deserve to be treated fairly under the law. over the past year, we've enacted a number of new rules to meet the mandates of the dodd-frank act including the qualified mortgage rule. this rule requires mortgage lenders to make a good faith reasonable determine nation that borrowers can actually afford to pay back their loans. we also enacted the mortgage servicing rule which is designed to clean up sloppy practices and p sure fairer and more effective processes for troubled borrowers. and we adopted a remittance rule that provides transparency and consumer protections for international money transfers
for the very first time. during this period, the consumer bureau has also been closely focused on making sure businesses both small and large have what they need from a practical and operational standpoint to understand and comply with the new mortgage rules. we put out plain pllanguage versions, created video guidance and met with market players including the vendors who serve many of our smaller institutions. we've worked with our fellow regulators to publish inter agency examination procedures well before the implementation date so industry understanding our expectations and has time to make necessary adjustments. we also have coordinated to ensure we all have a shared understanding to promote consistent supervision of compliance with the rules. while we work in all of these important efforts, we also recognize consumers bear their own share of responsibility for how they participate in the financial marketplace. we need to promote informed financial decision making. so we're providing consumers with useful tools including the
ask cfpb section of our website where we've developed answers to more than 1,000 frequently asked consumer questions. we encourage you to send your constituents to consumer finance.gov to get the benefit ofunbiased financial information. the premise is that consumers deserve to have someone tap on their side and see they're treated fairly.sttap on their side and see they're treated fairly.atap on their side and see they're treated fairly.ntap on their side and see they're treated fairly.dtap on their side and see they're treated fairly.ap on their side and see they're treated fairly.p on their side and see they're treated fairly. on their side and see they're treated fairly. que we've now received more than 230,000 consumer complaints. in the past year in fact we've received thousands of private student loan complaints and nearly 30,000 comments in response to our request for public information about how student debt is affecting individual consumers and the economy more generally. at a field hearing in miami on student loan debt, it became clear there are many troubling similarities to the mortgage
market. the burden of student debt is having a domino effect on our economy by jeopardizing the ability of young americans to buy home, start small businesses and save for the future. we consider it a priority to consider to closely monitor this market as it develops over time. the progress that we made in the past two years has been possible thanks to the engagement of thousands of americans who have used consumer education tools, submitted complaints, participated in rule makings and told us their stories through our website and as numerous public meetings from coast to coast. our progress has also been thanks to the cooperation of those we regulate. each day we work to accomplish the goals of renewing consumers' trust in the market place and ensuring that markets for consumer financial products and services are fair, transparent, and competitive. these goals not only support consumers as they climb the economic ladder. but also help responsible businesses compete on an even handed basis and reinforce the stability of our economy as a
whole. thank you for the invitation to appear before you today. as always, we welcome your oversight and i'm glad to have the opportunity to hear and address your concerns. thank you. >> thank you for your testimony. as we begin questions, i'll ask the clerk to put five minutes on the clock for each member. director cordray, the cfpb recently changed its qm rule to permit small lenders to make balloon payment qm rules regardless of geographic location until 2016. after 2016, the cfpb will only permit small lenders in rural or underserved areas to make balloon qm loans. i'm encouraged by the new transition. i'm concerned about how small lenders will be impacted in rural states like south dakota.
what process will the cfpb use to determine how to define a rural area? >> thank you, mr. chairman. this is one of the issues on which we got a lot of early feedback from the field from smaller institutions, both community banks and credit unions who lend in rural areas. we were attempting to implement rules that were proposed by the federal reserve, came to us to finalize. we determined that the definition of rural as it originally was proposed was too narrow and we broadened it substantially. we pretty much quintupled the percentage of the population that would be covered by the rural exception from 2.2% in the original proposal to i think 9.7% in our proposal. over time, we heard from folks that it was still viewed by them as too narrow and i saw maps of different counties in different states.
your state, that of rappingi cr ranking member crapo and my open state of ohio and other states, and i agreed that we had graun the definition too narrowly.cra and other states, and i agreed that we had graun the definition too narrowly.and my open state other states, and i agreed that we had graun the definition too narrowly.crapo and my open stat and other states, and i agreed that we had graun the definition too narrowly.ranking member cran state of ohio and other states, and i agreed that we had graun the definition too narrowly.mem of ohio and other states, and i agreed that we had graun the definition too narrowly. so we bumped that back to 2016 and made a commitment to reconsider how we had drawn rural in terms of being the department of agriculture al's urban and influence code, particularly counties that sush surround a metro poll tpolitan . the last thing we're looking to do is upset the kind of lending that goes on in rural areas that is pretty critical small towns, communities, villages across the country. >> well, i know have engaenlged in outreach to lenders before and after mortgage rules were
published. i want to make sure small lenders are not adversely impacted by these rules taking effect in january. can you describe whether you think lenders will be compliant by the january date and how the bureau will examine for compliance. >> it's a very fair question. there was a lot of rules that congress directed us to write. they gave us a fast timeframe. we had to have it in place by january 2013. notably if we had failed to do so, dodd/frank title 14 would have taken affect of its own force. people would have had to have lived under those laws already for the last 10 months. by enacting our rules we back that up for a year. we stayed close to the industry over the course of the year to understand practical, operational or interpretive problems they were running into in implementing the rules.
it is our clear sense from lots of discussions and ongoing input that the vast majority of institutions will be in substantial compliance with the rules by january 10th. that's both large and small with the smalls, many of them rely on lenders. we've been in close contact with the vendors to make sure they are ready. the other thing notable for qm rule, most important of these rules, we added an additional element that took effect in may which exempted institutions that make loans with less than $2 billion in assets, fewer than 500 mortgages a year, vast majority of community banks and credit unions. if they keep those in the portfolio, as many do, they will be qualified mortgages. if they keep them in the portfolio or sell them in secondary markets to gsc, which is a common thing tore them to do, they are in compliance. that was done specifically listening to them and
understanding we needed to do more to relieve burdens from institutions. we've attempted to taylilor our rules. we don't expect perfection. we're looking for good faith compliance, good faith efforts to come into substantial compliance by that date. >> the of consumer complaint database has been updated for a year. can you describe what safeguards have been put in place to make sure that the data is reliable. how do you envision it being used going forward? >> so, we have iterated that process. some of the concerns about the database in the early going were valid. when have you a small amount of information, not clear it's reflective or representative of what's going on in the country. when you get to having a larger
amount, it's kind of like pixels on a tv screen. the more there are, the more into focus the picture becomes. we've received more than 230,000 complaints and the picture is coming into much sharper focus. we continue to improve the system for verifying the relationship between the business organization and the consumer who is complaining. we don't put things into the database until they move through the entire process. we've had give-and-take with the institution. i think we continue to try to be responsive to the concerns people have raised while understanding the important function this serves. every business ought to pay close attention to the complaints customers bring onto them. good businesses do. we're seeing more an more reaction in the market where more emphasis put on that. therefore strong customer service, retention, that's a very good thing and we're encouraging that and promoting
it. >> senator. >> thank you, mr. chairman. director cordray, thank you for appearing before us today. probably not going to surprise you the first issue i want to get into is big data. director cordray, how many individual credit card accounts is the bureau monitoring using its supervisory authority on a monthly basis? >> i've been asked this question a number of times and i've said a number of times, that's not the way in which we proceed. we are not looking to monitor individual consumers credit card accounts, we have no interest in what individuals what you and i are spending or what our habits or patterns are. what we're trying to do is monitor practices of large institutions, how they treat things like late fees, interest rate changes and so forth for their customers. so we're looking from a standpoint of monitoring large institutions not individual consumers. >> i understand. i know you've answered it that way many times. isn't it correct the bureau has a contract with a data aggregator and you collect data
up to nine financial institutions. as i understand it, under your contract, you require the financial institutions to submit close to 100 data fields for each credit card you are monitoring -- account you are monitoring every month. is that not correct? >> it's roughly correct. what i would say, this is not something new we're doing that doesn't exist previously. we're simply accessing the very same set of information that has been developed privately by the private market that that ha been utilized by federal regulators. we're not when you say 100 fields, that's not something new or different. we haven't added a large number of additional fields, drawing on existing information. >> as i've gotten into this, i've realized there actually are other federal regulators seeking access to the same information. i understand that. that does not necessarily make it okay.
the bureau, as i understand it, has set a goal of monitoring 80% of the u.s. credit card market. just extrapolating from that using u.s. census bureau dat ark, that goal would represent 900 million credit card accounts. is that an accurate reflection of the bureau's goal and their activities in terms of reviewing credit card account activity? >> again, the bureau is not about reviewing any number of individual consumer accounts. what we're doing instead is illustrated by what we did a month ago. congress required us to do a report on the credit card industry and credit card market, to examine how it affected the market and report to you on how you can make policy and how you did with the card act, we can't do that without data. >> i understand that. i understand you want to focus it on the institutions and the market. but the fact is you are collecting data on individual
credit card accounts. is that not correct? >> we don't have any different data than the industry has itself, fellow regulators have. >> would the number of accounts be approximately 900 million credit card accounts? >> i don't know what number of the account is. again, that's not our focus. it's to oversee number of credit card issuers. >> independent the point. in order to achieve the purpose you describe, you are collecting individualized information, as we calculated, about 900 million accounts. i just want you to acknowledge whether or not that is correct. >> what i want to say to you is we're not doing anything new. the notion we're coming up with brand-new database or brand-new data or different in kind, it's not. >> would it be correct to say the snugs you have providing to you are providing to you on a monthly basis 100 data points on every credit card account that they manage? >> again, it would be accurate
to say what we are getting is the same thing fellow regulators have gotten and the same thing the industry itself is using to oversee -- >> i take your answer to be that is accurate and other institutions and private sector entities are doing the same thing. is that your answer? >> i don't dispute what you're saying. i think it's important to understand again, this is not about monitoring individual consumer behavior. i don't care about any individual, and we're not tracking anybody's credit card spending of any sort. what we're trying to do, if i'm going to oversee the largest financial institutions in this country and be able to take enforcement actions as we've done against a number of credit card issuers, we have to know what they are doing. we have to know what the effect is on the market. we have to know whether laws are being complied with. make no apologies, we need the data to do that. we cannot do it without the data. nor can we report what's
happening in the credit card market and make judgments or not. >> i understand that. i know you've given that answer multiple times. i just want you to state directly to us what -- as you collect this data, what the extent of individual account data it is you're collecting. is my description of it inaccurate? >> we are collecting, as i said, the same data already collected by federal regulators, nothing knew about that. the reach of it is such to give us confidence we can oversee the credit card market, know what the patterns of treatment are by financial institutions to consumers and protect consumers if, in fact, somebody is violating the law. >> director i take your answer to be i did correctly describe it. thank you. >> senator reid. >> well, thank you very much, mr. chairman. you mentioned in your opening statement the efforts you've undertaken to protect american
servicemen. i think the day after veterans day that's an important thing to do. i want to commend the work, one of the issues of military lending act, department of defense has authority to prescribe regulations but you're working with them. can you give us an idea of how you and petraeus are working with defense to provide more protection to service members? >> yes, senator. thank you for the question. what we're trying to do is faithfully implement the changes in the law you all brought about in december of last year, which reopen and allow updating the military lending act regulations so we can more broadly cover protections for service members on the use of consumer credit. we have been hard at work. there's been a drafting team. it is not limited to department of defense and cfpb representatives of major financial agencies including the ftc and treasury department. they have done exceptional work.
we're close to having a proposal to go out for public comment. there's a process of committing that product to omb for initial review before that happens. we're on track, on target. it's i think going to be the kind of work you expected and intended when you reopened military lending act last year. we're grateful for that. we've learned a lot from this process. >> just benefit what we're essentially trying to do is protect service members from interest rates on credit products above 36%. so it seems to me a very reasonable effort to make sure that protection is broad not narrow, 36% interest rate, we're not talking about something that is sort of competitive with some of the rates large institutions get daily. let me turn to another issue, that is there's obviously
growing concern, recent survey of national association of realtors suggest 49% of the respondents say ig aboutest hurdle of home ownership, not down payment but they have this student debt they won't be able to resolve. $1 trillion. what are you doing with respect to student deabt to refinance? >> this is an important issue for the future of this country. we have been among a number of officials agencies, what have you, who have been trying to call attention and gaining visibility with how the student loan debt problem, which now, as you say, exceeds -- it exceeds 1.2 trillion is affecting the economy in the country. i indicated in my written
testimony on the housing market, people's ability to move into the housing market. especially some of our college graduates who you would expect to be some of the folks hold be better position to do that. to form small businesses and to participate meaningfully in the economy, household and the like. we're seeing they are having a hard time entering into those pursuits, and it's because of the overhang of student loan debt. we have been at work, as i think you know, and talked previously about our efforts to bring more transparency and greater understanding to the student debt choices people make when they go to college and helping people manage the choices they have already made. they don't get to make them over again and they have an overhang of student loan debt. understanding their repayment options, their rights. understanding how if they are trying to pay that debt down faster, they can make sure allocated properly and servicers
aren't misallocating for whatever purposes, sometimes self serving. these are ongoing efforts of ours including the proposal we would supervise and examine student loan servicers in that market. again, very important work that we are doing with the department of education, to some degree department of treasury and others to get a handle on this probl problem. >> thank you. >> thank you for coming in for your report. back to senator crapo's questions. the materials that are coming in don't have an individual's name on them. is that correct? >> that's correct. >> it's a compilation of credit card activity within an institution with certain characteristics but doesn't identify that by individual. >> i think the phrases under standard anonymize, identified,
help us establish how institutions are treating customers not about how any individual customer decides to use their credit card. >> i want to go to some practices internally happen. the bipartisan policy center s has, you got high marks on rule making. you really went through a process. it was open. you got a lot of input. to my knowledge, most people are very happy with that process. dodd/frank also, though, made you do that. it was part of the process. there has been criticism, i'm sure you read it in the report, we're not doing that on other things. you were made to do that on one and the other it isn't occurring. all of us want the same thing, we want good practices out
there. i wondered if you wanted to publicly respond to the report on that issue. >> i would. what i would say is several things. i think in general what the bipartisan center said where you engage in a process that involves more openness and broader input, it tends to be a better process. you learn more and come away with better rules. that has been the process we've consistently followed on every one of our rule makings, including remittance rules where we went back and redid it to fix problems pointed out to us on all of our mortgage rules not just qm rules. we also have in other areas where we weren't obliged to do so gone out and sought significant public input. for example, we're going to be moving forward with debt collection rules. we're starting with a request for public information, which is a broad gathering of information before we get started. we've done that with prepaid cards and the like. >> if i could, since there's
just five minutes. they cite examples that is not happening. i would like since we're doing oversight to respond you plan to do that on all processes, not just the few you're referring to right now. >> so where i was going was on rule making, i think we've been open and successful. in areas were weren't required to do it, we've been open accessible. there's times we i should bulletins, not the same as rule making. they are not trying to change the law or figure how the law should be modified or improved, they are simply restatements of existing law. they are not themselves making, just clarifying or restating. for example, one of the items criticized was a fair lending bulletin we put out last year where we were simply joining with fellow regulators on this aspect of fair lending 16 years before and consistently adhered to it since as the justice
department as a new agency it was unclear what our approach would be. you under the law the same way. >> do you think any of the concerns expressed by this bipartisan group are merited? is there some work the agency needs to do to ensure diverse set of views you're dealing with? >> i do think there's merit on what they said. i think some of it was overstated in one direction. i think it's something important for us to think about and respond to not just verbally at a hearing but think about it in our work. for example, auto lending is an area of considerable sensitivity it appears. we have now scheduled and are going to be holding public forum on auto lending actually later this week in order to make sure we're engaging with key stakeholders in the area. i think that's an area where i
would agree with some of the criticism, a little more openness and transparency and we're going to divide that. >> thank you. i think there was another comment made about staff professionalism. i know you're gearing up. a lot of regulators has been around a long time, you have not. a lot has been to get back in a timely fashion when there are questions out there. some of the entities want to know what the response is going to be on the report. again, i assume you're building towards that overtime. is that correct? >> first of all, we weren't staffed up, only about 80% of where we intend to be on supervision personnel. that hampered us early going. we had a tradeoff we had to make a decision about. do we want speed or quality and consistency. we opted for quality and consistency somewhat at the expense of speed. i believe an industry will be finding, i think they are
already finding that we are now accomplishing both more readily. a year from now they will see more progress than they have seen in the last few months. >> thank you for those. i hope you'll get back before the next report on those issues. qm, basically you've laid out the outer limits on what consumers should be expected to pay back. anybody outside that limit could be subject to a lawsuit. that's what you did per qm rulings. do you think it makes sense in this body now looking at housing finance reform to use those same kinds of criteria as the outer limits as it relates to making loans because it makes no sense for federal agency to be involved in backing loans you've already said are the outer limits of what a consumer ought to be acknowledged to be able to
pay back. would that be a fair way of looking what we're doing? >> maybe. i want to tread carefully here. as you described, as i understand your question we're getting into areas really more subject to the federal housing finance administration and increasingly i think this congress says you're trying to figure out gsc reform and i see progress made there. i don't want to opine on things that do out my lane, but what i would simply say is in response to framework laid down on the statute there's qualified mortgage space and others not qualified mortgages but many of which are very responsible loans and should be made and have been made in the past and performed well particularly for smaller institutions. that's why we gave them a broad exemption and provision in the qm rule. so it's somewhat more complicated subject. i wouldn't feel that comfortable being seen as the expert in that area when we get into housing finance administration matters.
>> senator. >> thank you. director cordray, thank you for being here. this your first time testifying as a confirmed director. >> it doesn't feel much different. >> a little different. i want to thank our ranking member for the legislation i've been working on with senator moran and senator inhofe, johnson for his co-sponsorship. it's expressed, explored making change as part of the notice for request for information and streamlining regulations. how much of this change can be done by regulation versus legislation? are you supportive of congress moving on the legislation in this area and do you look at the
senate bill as providing adequate protection for consumers that we think it does. >> as i indicated, we have been looking at the privacy notices i should, in our streamline initiative. we indicated we plan to move forward with rule making on that issue in the fairly near future. can we do all the things congress could do in that area? not necessarily. we can do quite a bit of it. we certainly if congress acts in the area, we will faithfully implement what congress does. it reminds me a little bit of the atm sticker issue which came up over the last couple of years. we were fully prepared to move forward with rule making on that. congress ended up legislating on the issue last year, resolved it. we implemented that by rule. if that happens here, that's certainly fine by us. if that does not happen, not congressional action, we do plan to move ahead on that.
>> the senate bill does provide protections you've called for? >> we haven't fully -- since we're at the beginning of a potential rule making, we haven't fully defined exactly what our approach would be, but my sense is we're moving in roughly the same direction, yes. >> thank you. i held a hearing in july with our subcommittee examination debt collection which corey stone from your shop testified. last week released an advanced notice of rule making on reforms to the fair debt collection practices act. american bank quoted one collection executive saying it's unpleasant and sad we need this but i can fully appreciate where the cfp is headed. what are your issues on debt collection that need to be addressed including one area that senator reed mentioned on debt collection. >> senator, we're obviously
actively involved in this area and have been on other aspects of the bureau and senate enforcement as well. the debt collection market is similar to a number of other markets, not necessarily all in that you have a number of players responsible in trying to comply with the law and they feel undercut by the fact there are other participants in the market who don't have the same skr skr skrupels. that's not something we regard with much admiration at the consumer bureau. in the debt collection area, there's a couple of major concerns we identified in our advanced notice proposed rule making. one is accuracy of information that's accompanying these debts as they float around in the market. they may get contracted out to a third party debt collector, sold to someone who buys them and goes to collect on them.
if the information is not accurate, a consumer is being pursued for a debt they don't owe or a debt they may have paid or may be validly disputing and not recognized by the collector or debt buyer, that's a big problem. those things are getting reported on people's credit reports and potentially interfering with them accessing credit for mortgages, auto loans and the like. a second issue is just the way people are treated when they are being pursued on their debts. people should pay their debts. i'll be the first one to acknowledge that and that's important. we have 30 million people out of the financial crisis who have debts in collection, an average of $1400 apiece. just because people owe money and they are in circumstances doesn't mean they shouldn't be treated with dignity and respect. there are laws in place that may nottish entirely adequate to ensuring that occurs and we're going to review that and consider that as we go. i think it's a fundamental american principle people deserve to be treated with
respect regardless of their economic circumstances. >> thank you. thank you, director. >> senator. >> thank you, mr. cordray, for being here. you mentioned student debt. as you look at the student debt problem, have you collected data on the amount of student debt incurred that doesn't have anything to do with education. in other words, doesn't have anything to do with tuition, housing, food, sustenance and books. would you comment on that. >> good question, senator. we don't have any way to parse out exactly the way student loan debt is used by the student. we did have a field hearing in miami earlier this year at which there was some testimony that indicated there is a problem out there, that there are certain students who feel a lot of pressure from their families to maximize the amount of student loan money they can get because it may be necessary to support their families. it's not necessarily a wrong
decision for that family and those circumstances, but we've had some concern all along that some students may be borrowing more than they need for various reasons. sometimes they are encouraged and it's pushed on them to do so. sometimes they may be making a decision that may or may not be a good one. i don't know exactly how to collect data on that, other than maybe surveys but it's a question that would interest us a great deal. >> it's an important area. it may mean we need to modify some of the student debt parameters and restrict its use because my information has a large portion of this comes from lack of responsibility. it's available so i'll take it. they are not good stewards with the money they borrowed. >> it's possible. there's an issue, there's a certain amount of education debt incurred that's not student loans of it's hard to measure what the total magnitude of the problem is. a lot of people putting education debt on credit cards or home equity lines of credit.
so i think the student loan financing problem is even bigger than $1.2 trillion. >> qm rule statements in response to rule beyond january, good faith efforts with the law in early months and the vast majority of people are not having a problem with your rule. can you define for me what a good faith effort -- what you all are going to determine to be a good faith effort and what does early months mean? >> good faith effort here means the same thing it pretty much does in most supervision, which is we're looking for entities to have taken the responsibility seriously, compliance management systems in place, so this is something brought to the attention of the leadership and the board that there's monitoring in place around it. that doesn't mean every detail will be perfect at the level of execution, at the line level, but they have made real efforts
to put in place the rules, put in place the systems to monitor themselves for compliance with the rules. we expect them to be substantially in compliance, but we're not going to be playing a game of gotcha with people in the early months where they are still, perhaps, doing some training or implementing what their vendors have given them. >> there's some problems of software above $2 billion and 500 mortgages. getting this in. getting a clarification of early months. does that mean june or does that mean february? what does that mean for people? >> i haven't defined it. effective date is january 10th. we could have left it like that. by indicating how we intend to approach this, federal regulators approach supervision in early months. that's what we said. i'm not trying to pin it on a calendar here and would be kind of reluctant to do that here. early months would mean early
months several months after january 10th. >> can you explain for the committee why your new headquarters cost $95 million, twice what it was estimated, almost twice what it was estimated, contract for architecture, $7.2 million, what we're spending on your building alone almost entire gs affirm, entire rest of the country. can you tell me why we need a $95 million building? >> i think i can clear up a few points there. we never estimated renovation of that building, which by the way we do not own. i would rather not spend a penny on it. it has systems that outlived useful life like hvac and electrical that apparently have to be brought up to snuff. the $55 million figure was not an estimate of what that would cost but an initial budget number for the first year of what we saw as a multi-year
project. we don't know yet exactly what it will cost because there's processes unfolding, what our restrictions are for historic preservation, whether we can build on a seventh floor or not and other things. it's been a frustrating process for me. it's taken longer to get to understanding than i would like. we still don't have some of the decisions made by others made. it's not like our building, not like a palace for -- >> independent. i just note for the record the average is $316 square foot, average $150 per class aaa in this town, it's twice what it cost to renovate other buildings in this town. i'll drop that. >> be happy to have our staff talk to your taaffe about this. >> i'll be happy to work with you on that. >> okay. >> the other question i have for you, the employees that you've hired on average cost $42,000 more than the average federal employee with benefits. please explain that to me.
>> we're following the law, senator. the law requires us in dodd/frank to pay salaries and benefits comparable to those of the federal reserve and by extension the other agencies. that's what we are required to do. we would be out of compliance with the law if we didn't do that. the last i checked and understood, we were about 1% different from the average federal reserve salary, so i think we're doing a pretty good job being in compliance with the law. the banking agency pay scale is higher than that for the general government. that's been true for a long time. i think the thinking there, as i understand it, i wasn't around when that was created. if you're going to regulate the largest and most powerful financial institutions in the world, even though you can't keep up with their salaries, you need to be at least roughly able to hire people who can appropriately monitor.
we have lost some of them that have had their salaries tripled. for most part this is a system working well for us and other regulators and i'm com mike with the law on this. >> $172,700 per employee, i'll note for the record. >> that's not salary. that's salary, benefits combined. >> senator menendez. >> thank you, mr. chairman. one of my concerns doing dodd/frank was the marketplace had gotten ahead of where the regulators were, broadly defined. the intellectual and other firepower of the other regulators while good could not meet challenges of private marketplace way out there in developing instruments and a whole host of circumstances which really, in some cases, from my perspective, ran circles
around the regulators. it's important to have a staff that can actually go toe-to-toe with the universe. in that respect, director cordray, there are four economists, one from the university of chicago, nyu, occ, national university of singapore that recently released an independent valuation under the credit card acts, i strongly supported, many elements i authored. looking at the data from 150 million accounts, the study found huge benefits estimating the reforms are saving turms almost $21 billion per year. 21 billion per year. i was listening to the accounts. this is one area of $21 billion a year of savings. the average consumer's borrowing cost reduced by annualized 2% of
average daily balances. some of the people with the lowest fico scores found 10%. also found consumer's access to credit has not been reduced. so given the success, and i believe you've released your own -- the bureau has released its own report on the act and found similar successes. given the success of the credit card act reforms, what lessons can the bureau draw to protect consumers and improve transparency as it relates to credit cards and other financial products? >> thank you, senator. thank the entire congress for the work they did on the card act, which our report mandated to congress showed on october 1st has been largely successful at addressing the kinds of concerns they set out to address in the card act. when you all legislate you don't know whether you've got it right, solved the problems, what the effect will be in the market. now four years on we were able
to assess that. we cited one, two other studies all with similar message. so to me among the lessons are, number one, when there are problems and concerns how consumers treated in a mark, substantive changes in the law can actually address and eliminate or reduce problems to a considerable degree such as universal default and the way late payment fees were calculated and timed and the way rates were adjusting. a lot of that, as you say, has saved kur consumers a lot of money. the other thing when we go to save rules or law in financial area to protect consumers we're met with criticism it's going to dry up access to credit. nobody will lend if they have to protect consumers, like it's a horrible, unmentionable, impossible to understand objective. in this case, what we were able
to determine was that the access to credit issues were limited. to the extent there was constriction in access to credit parcelled out in the crisis which caused restrictions on access to credit, they were in terms of product lines utilized by consumers, there's still plenty of unused product line. it was cut back in that regard. some intended by the act. there were a lot of concerns about college students going off to college, leaving home, having credit cards actively marketed to them and getting into credit where they had no apparent income to repay. i remember when i was treasurer in ohio hearing a lot of heartburn about that. that was intended effect of the act to slow down the marketing of cards to young people and it has had that effect. >> i appreciate that. that was a pretty extensive answer.
let me in the few seconds i have left piggy back on that, a different card, prepaid credit cards. i had legislation i want to reintroduce again. i believe the bureau is considering possibility of regulatory actions in this arena starting with a request for public comment. this is also a very significant area where a lot of money guess spent and people don't know what they are buying. you have all types of fees beyond what i believe are necessary, certainly to make a profit. i understand why prepaid cards in that field. by the same token all types of fees from asking for your account balance to cancellation of the card and a whole host of other things above and beyond. can you give us an update on the status of the bureau's work in regard to prepaid cards.
what's your anticipate ory time line. >> we discussed your legislation. i expressed my view it's helpful in helping industry understand change is coming in the area of prepaid cards whether by legislation, bureau or regulation, one way or the other. indicating our commitment to engaging in regulation of prepaid cards, they are one of the problem areas in consumer financial protection because they are a hole in the current fabric. debit cards covered by law for protection, debit cards but prepaid cards are an odd new product and fall in the cracks. that's very problematic because this product has exploded in recent years. i've seen indications maybe as much as $175 billion will be loaded under prepaid cards by the end of next year. so we're playing catchup. it's important we put in place
regulations or legislation, either way, that make sure consumers get the benefits of disclosures, they got the benefit of error resolution, dispute resolution, the same kinds of protections they have on debit and credit cards. they would naturally assume on the prepaid credit cards but currently do not. >> thank you. i don't know if you have a quick answer here but for the record maybe you could quantify for us what the bureau has saved consumers through its actions in this country so we can look at a cost benefit relationship. >> i can't do that today. i don't know the answer to that. i hope and expect over time there will be considerable benefit to consumers. also nonquantifiable benefits like having your credit reports be right, not harassed in the workplace or relatives harassed by debt collectors, other things that go to the dignity of
individual consumers that is also important to them. thank you, chairman and thank you director cordray for joining us. quick question about the database senator crapo alluded to. my understanding is on a couple occasions federal reserve inspector general raised questions about data security and controls on data. i'm just won't earthquake, have you or do you intend to implement recommendations regarding data security on this database? >> we do. by the way, that's not solely the federal reserve's inspector general but cfg's inspector general, they have made a number of recommendations that have improved our operation. this is one of the areas where that is so. yes. >> have you already adopted their recommendations? >> we have been working to adopt their recommendations to
understand the basises for them and pay diligent attention you and senator crapo have raised surrounding privacy of this data. >> it's an ongoing process in the works. >> it is. it's an ongoing process. it may be we've implemented all those recommendations at this point. some take more time because they are more complex. we've also been looked at by outside auditors and will be looked at gao in response to ranking members request. if there are issues we want to make sure we're addressing them. if we're not different from other agencies in this regard, we'll know that. either way we take this very seriously. the fact you all raised this. i understand the agency has to get this right. if we don't, we'll be
undermining our mission. >> thank you. i want to go back to something senator raised. they stated, and i'll quote a little phrase here, when use a closed door process to issue guidance and has not gathered input from stakeholders, quality has suffered. i think you alluded to one case where you thought it would not be fair to include it in this critical category which was the issuing of a bullet defining practices unfair, abusive debt collection prags, ctices, if i follow that correctly. it seems to me the legislation authorizes you to define what are those practices. you did it through a bullet when it might have been done through a rule making process, or do i have that mistaken.
could you explain that to me? . there's rule making required when you're changing the law in some fundamental effect or not clear as before. when you're stating the law, not the one of i used but using the fair lending bulletin of last year as an example of clarifying we adhere to the same thinks of laws, fellow regulators. on debt collection a couple of different bulletins. one we first enforced credit card add ons, basis of a lot of $750 million in relief we've gotten from consumers. we issued a bulletin at the same time around the issue of deceptive marketing. you can try to define that for individual cases but the law is clear. it's the application to the facts that's the issue. that's something that typically
has to be done through enforcement or supervisory action. in terms of the debt collection bulletin that you're referring to where we indicated and made it clear what's already clear in the law, reminding, often say reminding institutions that third party debt collectors are covered by fair debt collection practices act but first party collectors are covered by -- had been covered by section 5 of ftc act before, now covered by dodd/frank act and they also were responsible when collecting debts in their own right for treating consumers fairly in compliance with the processes. we thought that was a mere restatement of the law. some people may take it differently. we are going to, as indicated before, be undergoing significant rule making project in many months ahead on debt collection which will clarify a lot of this further. >> it seems to me it's not
entirely retating existing law asked to define practices not defined in the law. i hear the point. my next question actually goes to this next phase, that is to the extent you make it more difficult or costly for lenders to recover portions of bad debts, that is very likely to end up being reflected in higher cost or less availability of credit as a general matter as lenders have to price that reality into their decision-making process. to what extent do you try to quantify that and weigh the cost to consumers who pay their bills on time and in full. do you do a cost benefit analysis, do you consider that a tradeoff and if so, how do you quantify that cost? >> that is something we will be engaged in in debt collection where we're going to be undertaking rule making as we
indicat indicated. we're required when we undertake rule making to consider benefits, cost, burdens of any proposed legislation. what you described in terms of how it could affect pricing, if people end up with a certain amount of debt they can't collect is a kind of consideration will be considered and weighed in that process. >> thank you, mr. chairman. director cordray, as you know there are nearly 60 million car loans outstanding for a total of $870 billion. for many families the car loan is the second largest loan outstanding. smaller than their mortgage but bigger than their student loans or credit card debt. now, car dealers don't finance most of these loans. instead they often absent as
intermediaries between buyers and financial institutions. buyer asking institution about financing, they turn around and ask financial institution for a quote and dealer passes the information back to the consumer. but too often the dealer gives the consumer a higher interest rate than the financial institution quoted and then pockets the difference. one study estimated that these costs aggregate more than $26 billion annually. that's $26 billion straight out of the pockets of working families every year. other studies found minorities are paying a higher share of those costs. now as you know, the cfpb has the authority to regulate nearly every kind of consumer loan but the big exception is car loans. i know they have indirect ways of getting at this problem. but a recent report from the bipartisan policy center, the report cited now several times
recommends congress close the loophole and give cfpb authority to make sure car loans are on the up and up. so my question is do you think that would be good for consumers? >> several thoughts, senator, in response to the question. i think you've laid out actually quite succinctly the kinds of concerns we have in this area. i would simply say when you say dealers get a quote and pass that information back to consumers. in fact typically they don't if the dealer gets a buy rate for 20%, they don't tell me that. they have 8 or 10 or 12% and not telling me the buy rate i qualified for based on my creditworthiness was 4%. that's one of the concerns we have in this area. the law we have is the law we're working with. when dodd/frank went through and
i wasn't in washington at the time and didn't see fascinating events unfolding that led to enactment of that law, there was apparently a compromise struck where auto dealers would not be subject to the jurisdiction of the consumer bureau but instead would be covered by ftc. but auto lenders were explicitly made subject to jurisdiction of the bureau. our efforts were to carry out what we understand to be our responsibility, to monitor the practices of auto lenders who if they set up a program whether either direct or indirect lending remained responsible for the effects of that program. that's what we're trying to do here. >> good. i appreciate that director cordray. cfpb has done great work and great work in the area as best we can. it makes no sense to me there should be any exception here for consumers who are being tricked out of billions of dollars every year on car loans.
i want to ask you about another issue. that is in september, i had the opportunity to participate in two military and veterans roundtables in massachusetts with holly petraeus, head of cfpb head of office of affairs. one issue for veterans is a growing scam involving the v.a.'s aid and attendance benefit, the benefit that helps cover the cost of nursing homes and in-home health aides for our disabled vets who don't have many resources. now, from what i understand the details of this scam are really grisly. a company offers to help a veteran sign up for the benefits. if the company determines the veteran has too many assets to qualify for the benefits, it tries to hide some of those assets by moving them to irrevocable trust or annuity that not only violates the spirit of the program, it often
ends up hurting the veteran. the company generally charges huge fees, takes a fat cut of whatever financial product they end up selling to the veteran and moves the assets where the vets can't easily reach them meaning the veteran is actually in much worse financial shape than before the person applied for help. i understand one case where a veteran got set up with an annuity that wouldn't start paying out until he was in his 90s. can you tell me what cfpb knows pout these scam artists and what congress could do to help stop them from preying on older veterans? >> thank you for that question. assistant director petraeus has seen these issues and educated all of us at the bureau about them, not just in massachusetts as you note and as you know but all over the country. these kinds of efforts to prey
upon what are seniors, also veterans, are beyond reprehensible. we think there are things we can do as a consumer bureau particularly working with state attorney general who has been pretty aggressive in the area and will continue to be if we highlight issues and problems for them, the state of washington, attorney general took a very helpful action on this. so has the state of oregon. we're going to try to coordinate others. in terms of what congress could do, i haven't thought that issue through. but anything you can do i think would be welcomed by us and others. we want to stamp this out and make sure people who are entitled to benefits, precious benefits that aren't that extensive under the law as it is, they have earned by serving their country are not going to be stripped of those by frauds and scams of the kind we see in
lots of markets but it one in particular. >> thank you very much. the aid and attendance benefit is a significant way we show our v veterans our appreciation. they are turning the benefit into something that undermines the financial security of our older veterans. i hope we can find -- i want to find a way to put an end to them. thank you, mr. chairman. >> senator moran. >> mr. chairman, thank you very much. director cordray, thank you for being here and the opportunity to ask you a couple of questions. you're aware in regard to automobile financing a number of us sent a letter to you to consumer protection financial bureau, that letter was dated october 30th. it was signed by 21 or 22 of us requesting information you've responded. thank you for your response. but i want to follow up and see if you can provide a broader answer and perhaps a more specific answer. what we ask in that letter was
for details concerning the statistical methodology the bureau employs to determine whether dispariate impact portfolio methodology for each group of consumers the bureau has examined. what i know is that the borrowers don't self-identify. they don't say their gender or their race. you are using, the bureau is using a proxy to determine those criteria. but apparently a conclusion has been reached there is discrimination or disparate finance charges based upon those characteristics. you describe in the letter back to us the nature of that analysis. but one of the things we ask for is the evidence that that use of the proxy is providing an
accurate methodology to reach the conclusions that you are reaching. has there been analysis done to demonstrate that the proxy is providing accurate information for which you are now basing decisions on? >> yes. thank you, senator. it's a somewhat complex area. however, several things. number one, we are using an approach that is sort of time honored and well tested both in social science literature and by the justice department and our fellow regulators. there was a webinar which the head of our fair lending participated with federal reserve and proxy methodology they use is very similar to ours, ours is refined in a couple of respects. they are not exactly the same but very much in harmony. we're going to be having as i said now in response to some of the concerns raised by you and
others an auto forum on thursday in which more of this will be aired out and the major players in the industry will have a chance to probe issues with us. again, our approximatel methodology is something used not just in these kinds of lending cases but in a variety of other cases, employment discrimination cases and others and is considered to be state-of-the-art. people may have their issues with state-of-the-art. we're not embarking on some novel or untested or brand-new approach here. >> let me see if i understand what you're telling me. the approach, according to what you're saying is -- i've been around a while. it's regarded, considered to be accurate. has the bureau done specific analysis on the data collected to confirm that in this case? >> we have scrubbed the proxy
methodologies that are used. we've refined them to some degree to include elements of census tracked render precise data. i want to be careful to talk about what we found. this is an ongoing investigative effort where we're working with the justice department. so the order of the day on those things is confidentiality unless or until you get to the point of taking some sort of public action. so i wan to be a little careful about not preaching that. but yes, we have looked very carefully at what we're doing and trying to understand prior approaches that are approaches in line, that that approach is accurate and calibrated to the >> understanding that anything we do could ultimately be tested in court and court would have to have confidence in our methods. >> i was going to critique the idea of having a financing seminar on thursday, but you eve
already responded by saying it's a result of our inquiries that you're doing it. i was going to -- >> if you have any suggestions, feel free to make them, yeah. >> earlier in the process might have made more sense. >> maybe. >> but if you're giving us credit for raising these issues and, in response, you're having thursday's program, you've somewhat taken the wind out of my sales. it does seem to me that this is the kind of conversation that should have taken place before this week. >> i'll just say, one of the complexities for us and senator warren eluded to the issue, under our statute, what's very clear is we do not have jurisdiction over autodealers. we do have jurisdiction and understand it to be a responsibility under the law to monitor and oversee autolenders. that's complex for us. we don't want to be misperceived as somehow trying to extend our
reach over autodealers which congress very carefully put on one side of the line. however, we don't feel that we can fail to exercise our duty with respect to autolenders who are on our side of the line. so the reaching out we might have naturally done has been difficult for us because we don't want to be greeted by there they go, they think they now control autodealers. we know that we don't. we're trying very hard to observe the line congress true. it's not a natural line, as senator warren mentioned. but it's in the law and that's something we're trying to be careful about. >> i appreciate that difficulty. let moe just poent oint out again, in this arena, what senator toomey was trying to address in a broader sense, i want to make certain that there will be analysis about the increasing costs or the increasing interest rates that may be charged consumers if you
move to a flat-fee financing system. under the theory that, as senator toomey said, consumers will pay for those increasing costs. and we -- i assume that you would confirm that analysis is necessary to avoid increasing the costs so that consumers don't, while your efforts may be to eliminate discrimination, if fewer consumers can borrow money to purchase a car, we've done a lot of damage to consumers and to the economy. >> i think that's a fair point. it's the same point that we ran up against as we wrote our mortgage rules. you want to impose the right protections, make sure people are treated fairly and particularly want to make sure that they're treated in a nondiscriminatory basis. but we don't want to dry up access to credit.
i will say, and i think it's notable. people have been reacting to our fair lending bull tietin on autolending going back as far as the spring and concerned about what the impact may be, the autolending market is red hot right now. we're selling more cars than we have in a number offiers. i believe that will continue. we cheer that on at the consumer bureau. for a lot of people, autos mean opportunity. it means being able to get back and forth to work. its's basic functional part of existence, being able to get around. and we understand that credit means opportunity for a lot of consumers if it's used responsibly. we also want to make sure that when a consumer goes in to get a loan to buy a car that they aren't unwittingly being forced to pay more based on assumptions made about their racial or ethnic background. and i think that's a very
bedro bedrock, american principle, as welt. we'll be taking great care as to how we move forward here. but we think that there are some key core american principles at stake. >> senator ritter? >> thank you, mr. chair. and thank you, director, for being here. i want to go back to a topic that several members touched on, which is the massive data collection your agency is in the midst of. and i apologize if i repeat any questions. but i cothink it's important. so i do think it merits the time, at least. during your april 23rd appearance before us, i believe you asserted clearly that cfpb is not collecting personally identifiable financial information about consume rs. is that correct? or incorrect? >> no, i don't believe that i
said that because that's not, in fact, correct. there's some very limited areas where we do have a certain amount of personal, identifiable information which as you know is a term of art under federal law. consumers come to us and they provide personal, identifiable information in order to make a complaint and have it be processed. they give us their name, they give us their address, they may give us their bank account information or social security number, whatever is necessary to process that complaint. and it's very important for us to make sure that that information is safeguarded from a security and a privacy standpoint. and we've been as careful as we can to do that. >> but what about other broad categories like information you collected about credit card transactions or mortgages. >> that information is de-identified, as apparently a it term of art.
we are not interested with the credit card data. a ranking member and i had a colloquy about this earlier. we don't need or want to know what you and i or other individuals are spending or what our patterns of behavior are. what we're looking for is the kind of information that will allow us to oversee the financial institutions. how they're treating their customers. are they complying with the law? what is the pattern of late fees and interest rates. it's the same data we used to fulfill our responsibility to congress. you all mandated that we do a report on the state of the credit card market and the e k effects of the card act. >> say all the data you collect about mortgages or credit card accounts s none of that searchable by personally identifiable information? >> my understanding is that none of that data has personally identifiable information. and therefore, not be searchable by it. that's correct. that's our intention, and i
believe that is, in act, the case. >> i look at what appears to be conflicting information. can you go and double check that and report to us in the record by listing exactly what categories do have personally identifiable information? and what other categories do not have personally identifiable informs. >> yeah. >> so, as i'm sure you would imagine, this is an issue that people worked to prepare me for carefully for a hearing like this. the two areas where we have some personally identifiable information are the consumer complaint area, where it's inevitable. that's what it is. it's an individual identifying their personal situation so that we can seek to acress it. in the supervisory area, we end up with personally identifiable information. if we're cleaning up a list of consumers who were victimized by the practice to make sure that
relief is going to the right individuals, that sort of thing, some of that is just necessary. but in terms of our data collection, which is i think the focus, if i understand it, of some of the sensitivity that we're supposedly collecting this mass amount of credit card informers or medical report gablg information. all of those efforts are done to monitor on an anonymous, de-identified basis. again, we're not interested in. it is not part of our effort to understand what an individual consumer is doing or somehow track or follow their practices. that's just not help vl for us. if we had, it would only complicate our efforts there. rather than just shooting in the dark, that's essentially what we're trying to do there. >> if you can supplement for the record, the complete lists in each category. st